IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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Foreign subsidiary receives late disregarded-entity election relief
A foreign eligible entity intended to be treated as disregarded from its sole owner and consistently reported that way, but inadvertently failed to file Form 8832 on time. The entity represented…
Governmental employee-benefit trust income excluded from tax
Political subdivisions created a trust to fund health and welfare benefits for current and former employees and their families. The IRS ruled that providing those benefits was an essential…
Entity receives more time to elect corporate classification
An eligible entity intended to be treated as an association taxable as a corporation but inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied the standards for…
Foreign entity receives late disregarded-status election
A foreign eligible entity with one owner intended to be treated as a disregarded entity for federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found that the entity…
Foreign entity receives late disregarded-status election
A foreign entity was indirectly and wholly owned by one owner and intended to elect disregarded-entity status from its formation date. It inadvertently failed to file Form 8832 on time. The IRS…
Foreign entity receives late disregarded-status election
A foreign entity was indirectly and wholly owned by one owner and intended to elect disregarded-entity status. It inadvertently failed to file Form 8832 on time. The IRS found that the entity…
Foreign entity receives late disregarded-status election
A foreign entity had one owner and intended to elect disregarded-entity status. It inadvertently failed to file Form 8832 on time. The IRS found that the entity satisfied the regulatory-election…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign subsidiary receives late disregarded-status election
A domestic limited liability company treated as a partnership wholly owned a foreign subsidiary. The subsidiary intended to elect disregarded-entity status from its formation date but failed to file…
Foreign entity receives late partnership election relief
A foreign eligible entity intended to be classified as a partnership for federal tax purposes from its formation date but failed to file Form 8832 on time. Its owners consistently treated it as a…
Foreign entity may make late partnership election
A foreign eligible entity whose owners had limited liability intended to be treated as a partnership for U.S. federal tax purposes but inadvertently failed to file Form 8832 on time. The IRS found…
Foreign entity receives 120 days for late disregarded status
A foreign entity and its owner intended from formation to treat the entity as disregarded for U.S. federal tax purposes. The owner consistently filed returns on that basis, but the entity had not…
Foreign entity receives 120 days for partnership status
A foreign entity with two owners intended from formation to be treated as a partnership for U.S. federal tax purposes. Its U.S. owner consistently filed returns on that basis, but the entity had not…
Foreign entity receives 120 days for late disregarded status
A foreign entity and its sole owner intended from formation to treat the entity as disregarded for U.S. federal tax purposes. The owner consistently filed returns on that basis, but the entity had…
Foreign entity gets late disregarded status before partnership
A foreign entity was wholly owned by one owner from formation and was intended to be disregarded for U.S. federal tax purposes. A second owner later acquired an interest, after which the owners…
Indirectly owned foreign entity gets late disregarded status
A foreign entity was owned by a foreign disregarded entity and indirectly by a U.S. corporation. The owners intended from formation to treat the lower-tier entity as disregarded, and U.S. returns…
Foreign entity receives 120 days for partnership status
A foreign entity with two owners intended from formation to be treated as a partnership for U.S. federal tax purposes. The owners consistently filed returns on that basis, but the entity had not…
Extensions granted for QSub and entity-classification elections
An S corporation failed to timely elect qualified subchapter S subsidiary status for a wholly owned entity, and related entity-classification elections also were not timely made. The IRS concluded…
Foreign entity received 120 days to file corporate classification election
A foreign entity intended to elect corporate tax classification effective on a specified date but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good…
Late disregarded-entity election receives 120-day extension
A foreign entity intended to be treated as a disregarded entity for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that its returns were consistent with the…
Late corporate classification election receives 120-day extension
A foreign entity intended to elect classification as an association taxable as a corporation but failed to file Form 8832 on time. It represented that it acted reasonably and in good faith, did not…
Disregarded LLC employees may join parent's 403(b) plan
A tax-exempt health system planned to convert a nonprofit hospital subsidiary into a single-member limited liability company. The LLC would not elect corporate status and therefore would be…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late disregarded-entity election granted
A foreign limited company with one nonresident-alien owner intended to elect disregarded-entity treatment but did not file Form 8832 on time. The IRS concluded that the requirements for…
Late disregarded-entity election granted
A foreign entity intended to be treated as a disregarded entity from its formation date but failed to file Form 8832 on time. The IRS concluded that the requirements for discretionary relief under…
Late disregarded-entity election granted
A foreign entity intended to be treated as a disregarded entity from its formation date but failed to file Form 8832 on time. The IRS concluded that the requirements for discretionary relief under…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late entity-classification election granted
A foreign entity intended to elect corporate classification for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it acted reasonably and in good faith and…
Late partnership-classification election granted
An eligible domestic entity intended to be treated as a partnership for federal tax purposes but did not file Form 8832. The IRS concluded that the requirements for discretionary election relief…
Late foreign disregarded-entity election granted
A foreign limited company had initially elected corporate classification but later intended to become a disregarded entity. It failed to file Form 8832 by the deadline for the requested effective…
Disregarded LLC employees may join parent's 403(b) plan
A section 501(c)(3) hospital system wholly owned a home-health LLC that had not elected corporate tax treatment. The parent asked whether the LLC's employees could participate in its section 403(b)…
Foreign entity receives late disregarded-entity election relief
A foreign limited company owned by a nonresident alien failed to timely file Form 8832 to elect disregarded-entity status. The IRS found that the company met the standards for discretionary election…
Foreign superannuation fund is classified as a trust
A foreign arrangement was organized to provide retirement benefits to its members and beneficiaries. Trustees managed employer and employee contributions and investment income, with duties to…
Foreign superannuation fund is classified as a trust
A foreign arrangement was organized to provide retirement benefits to its members and beneficiaries. Trustees managed employer and employee contributions and investment income, with duties to…
Foreign superannuation fund is classified as a trust
A foreign arrangement was established to provide retirement benefits to its members and beneficiaries. Trustees managed employer and employee contributions and investment income, with duties to…
Foreign entity receives late corporate classification election relief
A foreign eligible entity intended to elect association taxable as a corporation status but failed to timely file Form 8832. The entity represented that it acted reasonably and in good faith and…
Foreign entity receives late disregarded-entity election relief
A single-owner foreign eligible entity failed to file Form 8832 on time to elect disregarded-entity status. The IRS found that the entity satisfied the standards for regulatory-election relief. It…
Late disregarded-entity election granted
A foreign eligible entity was formed for a trust and had one owner. The entity, the trust, and the trust's grantor intended from formation to treat the entity as disregarded for federal tax purposes…
Late disregarded-entity elections granted for twelve foreign entities
A domestic corporate parent formed or acquired twelve wholly owned foreign eligible entities and consistently reported their activities, assets, and liabilities as if they were disregarded entities.…
Foreign entity received more time to elect disregarded status
A foreign eligible entity intended to be treated as disregarded from its owner for U.S. federal tax purposes but inadvertently failed to file Form 8832 on time. The entity represented that it acted…
Foreign entity received 120 days to elect disregarded status
A foreign eligible entity intended to elect treatment as a disregarded entity for U.S. federal tax purposes but did not timely file Form 8832. It represented that the late request did not involve…
Foreign entity received more time to elect corporate status
A foreign eligible entity intended to elect treatment as an association taxable as a corporation for U.S. federal tax purposes but inadvertently missed the Form 8832 deadline. It represented that it…
Foreign entity received late disregarded-entity election relief
A foreign single-owner entity intended to be classified as disregarded for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it was eligible to make the…
Foreign entity received late disregarded-entity election relief
A foreign single-owner entity intended to be classified as disregarded for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it was eligible to make the…
Foreign entity received late disregarded-entity election relief
A foreign single-owner entity intended to be classified as disregarded for federal tax purposes but inadvertently failed to file Form 8832 on time. It represented that it was eligible to make the…
Foreign regulatory trust is owned by its CFC grantor
A controlled foreign corporation established a foreign-law trust to segregate and conservatively invest assets required to support its regulated business obligations. A separate trustee managed the…
LLC received late corporate classification election relief
A limited liability company intended to elect corporate tax classification effective from its formation date but inadvertently failed to file Form 8832 on time. The IRS found that the company…
Late entity-classification election receives relief
A single-owner limited liability company intended to be classified as an association for federal tax purposes but did not timely file Form 8832. It represented that all U.S. tax and information…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.